FAC Explorer

Finding 1238032 (2025-009)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-29
Audit: 412843
Organization: County of Allegheny, Pennsylvania (PA)
Auditor: ZELENKOFSKE AXELROD LLC

AI Summary

  • Core Issue: Some housing units charged rents above comparable units, and many lacked proper documentation to prove rent reasonableness.
  • Impacted Requirements: Compliance with HUD's rent reasonableness criteria is essential for federal rental assistance eligibility.
  • Recommended Follow-Up: DHS should enhance policies, training, and monitoring to ensure all providers meet HUD requirements and maintain compliance.

Finding Text

Continuum of Care — AL #14267 Special Tests Condition: Our testing of Rent Reasonableness for a sample of three DHS providers operating 90 housing units for the month of May, 2025 identified that: - 3 (3%) units had rent being charged that was higher than the rents of the comparable units. - 36 (40%) units lacked appropriate documentary evidence that rent reasonableness had been substantiated prior to executing the lease. Criteria: HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units (24 CF R 578.51 (g)). Cause: In a prior year DHS developed and implemented its own rent reasonableness policy and provided a rent reasonableness policy template to the Continuum of Care program providers to facilitate their development and implementation of such policies. However, during the prior year’s audit we determined that DHS did not take adequate measures to ensure that all Continuum of Care program providers had implemented and were adhering to appropriate rent reasonableness policies. We have been advised that DHS is still working with providers to ensure that they are adhering to HUD’s rent reasonableness requirements. Effect: The County was not in compliance with the terms of the federal grant program. Questioned Costs: None Recommendation: DHS should continue to work with providers to ensure that they are adhering to HUD’s rent reasonableness requirements. By strengthening policies, training, and monitoring, the program will enhance compliance with HUD requirements, ensure rational rent payments, and safeguard federal housing assistance funds. Management Response: Management agrees with the finding, see attached Corrective Action Plan.

Corrective Action Plan

Corrective action steps taken and/or planned: Programs were instructed to update all current client files to include the rent reasonableness studies, and this should happen annually when the lease is renewed o r any time a client needs to m o v e t o a n o t h e r unit. Providers a r e also n o w maintaining a r e n t reasonableness tracking sheet with all rent related information f o r units considered f o r t h e rent reasonableness analysis. Also, during each m o n t h l y invoice review, program staff look a t each rent payment within each grant and flag any rents that seem excessive and reach out to the provider with any questions. If the rent is deemed too high o r ineligible, we will ask the provider to remove the amount from the invoice. We also have an updated, HUD approved, Rent Reasonableness policy, which has been provided to all housing providers. Timetable of dates for performance of planned corrective action steps including completion date: Active. The communication of the process changes to housing providers had occurred and monitoring is taking place. Since 2024, our office has made a full push regarding monitoring of the providers, especially related to rent calculations and rent reasonableness policies and procedures. Our Fiscal Specialist has accompanied our monitoring team throughout their technical assistance season (Nov2025 — Feb2026) and the actual monitoring season (Feb2026 — still ongoing but wrapping up in July). Fiscal Specialist has worked with the provider’s fiscal staff to create, revise and maintain new policies and procedures to ensure rent reasonableness processes are completed. We will continue to monitor these items specifically throughout 2026 and beyond. E. Description of monitoring to be performed to ensure corrective action steps are taken: Program monitors have added the Rent Reasonableness test to their annual monitoring. This has also been added to our Fiscal Monitoring, which is done annually as well, but with more focus on invoicing a n d contracting. During Fiscal Monitoring, some leases a r e reviewed to e n s u r e all items are covered along with the rent reasonableness. We will continue to work with providers to ensure they are adhering to HUD’s requirements. We will continue to monitor their policies and train them to enhance their compliance in order to continue to utilize these much needed federal funds.

Categories

Subrecipient Monitoring HUD Housing Programs

Other Findings in this Audit

  • 1238019 2025-012
    Material Weakness Repeat
  • 1238020 2025-012
    Material Weakness Repeat
  • 1238021 2025-012
    Material Weakness Repeat
  • 1238022 2025-011
    Material Weakness Repeat
  • 1238023 2025-003
    Material Weakness Repeat
  • 1238024 2025-004
    Material Weakness Repeat
  • 1238025 2025-005
    Material Weakness Repeat
  • 1238026 2025-006
    Material Weakness Repeat
  • 1238027 2025-007
    Material Weakness Repeat
  • 1238028 2025-014
    Material Weakness Repeat
  • 1238029 2025-015
    Material Weakness Repeat
  • 1238030 2025-016
    Material Weakness Repeat
  • 1238031 2025-008
    Material Weakness Repeat
  • 1238033 2025-001
    Material Weakness Repeat
  • 1238034 2025-002
    Material Weakness Repeat
  • 1238035 2025-001
    Material Weakness Repeat
  • 1238036 2025-002
    Material Weakness Repeat
  • 1238037 2025-001
    Material Weakness Repeat
  • 1238038 2025-002
    Material Weakness Repeat
  • 1238039 2025-010
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $38.23M
14.267 CONTINUUM OF CARE PROGRAM $25.57M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $24.19M
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $19.77M
93.658 FOSTER CARE TITLE IV-E $18.99M
93.563 CHILD SUPPORT SERVICES $18.60M
93.600 HEAD START $15.62M
93.659 ADOPTION ASSISTANCE $14.61M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $13.31M
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $12.75M
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $9.63M
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $8.65M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $7.69M
93.667 SOCIAL SERVICES BLOCK GRANT $6.89M
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $5.10M
93.090 GUARDIANSHIP ASSISTANCE $4.40M
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $3.76M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $3.19M
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $3.17M
93.788 OPIOID STR $3.03M
97.067 HOMELAND SECURITY GRANT PROGRAM $2.39M
66.001 AIR POLLUTION CONTROL PROGRAM SUPPORT $1.78M
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $1.54M
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $1.49M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.45M
14.905 LEAD HAZARD REDUCTION DEMONSTRATION GRANT PROGRAM $1.42M
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $1.40M
16.045 COMMUNITY-BASED VIOLENCE INTERVENTION AND PREVENTION INITIATIVE $1.33M
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $1.22M
93.569 COMMUNITY SERVICES BLOCK GRANT $1.21M
14.889 CHOICE NEIGHBORHOODS IMPLEMENTATION GRANTS $1.10M
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $1.08M
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $1.01M
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $965,607
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $960,390
93.304 RACIAL AND ETHNIC APPROACHES TO COMMUNITY HEALTH $900,024
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $889,142
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $720,008
93.104 COMPREHENSIVE COMMUNITY MENTAL HEALTH SERVICES FOR CHILDREN WITH SERIOUS EMOTIONAL DISTURBANCES (SED) $687,352
16.922 EQUITABLE SHARING PROGRAM $649,519
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $639,707
94.016 AMERICORPS SENIORS SENIOR COMPANION PROGRAM (SCP) 94.016 $604,506
94.006 AMERICORPS STATE AND NATIONAL 94.006 $555,067
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $549,598
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $414,724
66.034 SURVEYS, STUDIES, RESEARCH, INVESTIGATIONS, DEMONSTRATIONS, AND SPECIAL PURPOSE ACTIVITIES RELATING TO THE CLEAN AIR ACT $342,976
14.881 MOVING TO WORK DEMONSTRATION PROGRAM $330,044
93.778 GRANTS TO STATES FOR MEDICAID $320,811
16.742 PAUL COVERDELL FORENSIC SCIENCES IMPROVEMENT GRANT PROGRAM $306,213
16.812 SECOND CHANCE ACT REENTRY INITIATIVE $283,132
93.940 HIV PREVENTION AND SURVEILLANCE ACTIVITIES-HEALTH DEPARTMENT BASED $264,936
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $262,418
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $262,164
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $260,257
93.334 THE HEALTHY BRAIN INITIATIVE: TECHNICAL ASSISTANCE TO IMPLEMENT PUBLIC HEALTH ACTIONS RELATED TO COGNITIVE HEALTH, COGNITIVE IMPAIRMENT, AND CAREGIVING AT THE STATE AND LOCAL LEVELS $243,450
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $240,957
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $221,270
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $217,850
93.977 SEXUALLY TRANSMITTED DISEASES (STD) PREVENTION AND CONTROL GRANTS $213,467
16.575 CRIME VICTIM ASSISTANCE $206,030
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $197,552
16.741 DNA BACKLOG REDUCTION PROGRAM $188,976
16.838 COMPREHENSIVE OPIOID, STIMULANT, AND SUBSTANCE USE PROGRAM $188,165
16.833 NATIONAL SEXUAL ASSAULT KIT INITIATIVE $173,688
93.070 ENVIRONMENTAL PUBLIC HEALTH AND EMERGENCY RESPONSE $153,620
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $103,544
66.312 ENVIRONMENTAL JUSTICE GOVERNMENT-TO-GOVERNMENT (EJG2G) PROGRAM $98,710
93.791 MONEY FOLLOWS THE PERSON REBALANCING DEMONSTRATION $93,567
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $91,454
93.823 PUBLIC HEALTH RESPONSE, FORECASTING, AND ANALYTIC CAPACITIES RELATED TO DISEASE OUTBREAKS, EPIDEMICS, AND PANDEMICS $91,169
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $81,780
93.324 STATE HEALTH INSURANCE ASSISTANCE PROGRAM $81,492
14.921 OLDER ADULTS HOME MODIFICATION GRANT PROGRAM $73,284
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $61,495
93.048 SPECIAL PROGRAMS FOR THE AGING, TITLE IV, AND TITLE II, DISCRETIONARY PROJECTS $60,679
93.071 MEDICARE ENROLLMENT ASSISTANCE PROGRAM $58,876
16.036 COMPREHENSIVE FORENSIC DNA ANALYSIS GRANT PROGRAM $54,558
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $47,471
16.609 PROJECT SAFE NEIGHBORHOODS $35,903
93.853 EXTRAMURAL RESEARCH PROGRAMS IN THE NEUROSCIENCES AND NEUROLOGICAL DISORDERS $35,298
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $34,000
14.906 HEALTHY HOMES TECHNICAL STUDIES GRANTS $30,000
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $29,698
93.197 CHILDHOOD LEAD POISONING PREVENTION PROJECTS, STATE AND LOCAL CHILDHOOD LEAD POISONING PREVENTION AND SURVEILLANCE OF BLOOD LEAD LEVELS IN CHILDREN $24,766
93.738 PPHF: RACIAL AND ETHNIC APPROACHES TO COMMUNITY HEALTH PROGRAM FINANCED SOLELY BY PUBLIC PREVENTION AND HEALTH FUNDS $23,078
66.956 TARGETED AIRSHED GRANT PROGRAM $21,856
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $19,918
93.945 ASSISTANCE PROGRAMS FOR CHRONIC DISEASE PREVENTION AND CONTROL $17,888
20.703 INTERAGENCY HAZARDOUS MATERIALS PUBLIC SECTOR TRAINING AND PLANNING GRANTS $15,199
23.002 APPALACHIAN AREA DEVELOPMENT $14,613
16.560 NATIONAL INSTITUTE OF JUSTICE RESEARCH, EVALUATION, AND DEVELOPMENT PROJECT GRANTS $13,797
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $11,041
10.572 WIC FARMERS' MARKET NUTRITION PROGRAM (FMNP) $8,466
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION€™S HEALTH $7,896
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $4,979
93.008 MEDICAL RESERVE CORPS SMALL GRANT PROGRAM $262
90.404 HAVA ELECTION SECURITY GRANTS $-248
17.259 WIOA YOUTH ACTIVITIES $-29,056
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $-32,504